Your Quick Guide To Managing Ethics & Compliance

Emerging bribery & corruption schemes

ABC – Getting Tactical

I had a helpful call with an anti-money laundering specialist a few weeks back. He explained how peers cooperate to share intelligence about emerging criminal/terrorist tactics. When I started in risk, we’d do likewise with terrorist tactics. The AML expert asked, do you do the same for anti-bribery, fraud, and the like?

Yes and no. Anecdotally, I’ve accumulated an expanding library of war stories, but I’d be lying if I said I’d categorised, catalogued and analysed them, looking for trends, triggers and predictors.

In a newsletter, we won’t get there. But on the current roster of trends and tactics in bribery and corruption, I might offer the following:

🚦 Misuse of cryptocurrencies and digital assets to make illicit payments anonymously.

🚦 Exploiting loopholes in vendor onboarding processes to create fake consulting agreements or service contracts.

🚦 Sophisticated hacking of accounts payable systems to approve and divert fraudulent payments.

🚦 Manipulating invoices and purchase orders to overstate or falsify services/goods provided.

🚦 Abusing charitable donations as a conduit for bribes to gain influence.

🚦 Leveraging software vulnerabilities to manipulate quality/safety testing data.

🚦 Exploiting government stimulus and assistance programs with fake beneficiaries and data.

🚦 Bribery disguised as regular promotional expenditures for gifts, travel, and entertainment.

Aren’t some of these old? Yes, for large and sophisticated organisations with decades of internationalised experience, many might appear familiar. But, much of my work these days is with SMEs (and investors in SMEs). These tactics are migrating down value chains as more prominent organisations become more challenging targets.

What would you add?

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Your Quick Guide To Managing Ethics & Compliance